International Tax

U.S. Approves Long-Awaited Tax Treaties with 4 Ally Countries by James W. Spencer, CPA

Posted on September 27, 2019 by Jim Spencer

In the summer of 2019, the U.S. ratified updates to international tax treaties with four of the country’s allies that had been awaiting Senate approval for nearly a decade. The move yielded a collective sigh of relief from multinational businesses and their shareholders in Spain, Switzerland, Japan and Luxembourg that had been operating in an […]

Wayfair Decision Imposes New State Tax Burden on Foreign Businesses Selling into the U.S. UPDATED by Karen A. Lake, CPA

Posted on September 24, 2019 by Karen Lake

The U.S. Supreme Court’s 2018 decision in South Dakota v. Wayfair has had far-reaching impact on the state and local sales tax (SALT) obligations and previous competitive advantages of online and foreign businesses that sell products into the U.S. The court’s ruling eliminated the prevailing physical presence test, which required sellers to collect sales tax […]

Multinational Business May Want to Rethink Entity Choice and Other Elections by Andrew Leonard, CPA

Posted on August 22, 2019 by Andrew Leonard

The overhaul of the U.S. tax code was signed into law at the end of 2017, yet many taxpayers are continuing to conduct business as usual, paying little attention to how the new law impacts their tax liabilities for 2018 and beyond. To be sure, the Tax Cuts and Jobs Act (TCJA) in its original […]

Are U.S. Visa Holders Subject to U.S. Income and Estate Taxes? by Eden Abitan, CPA, CGMA

Posted on June 11, 2019

For many foreign persons, the U.S. tax system can be a complicated web of conflicting rules and exceptions, making compliance difficult, at best. One of the more complex challenges concerns the U.S.’s different treatment of foreign persons for income tax and estate and gift tax purposes. In general, the U.S. presumes foreign persons to be […]

IRS Enhances Security, Revises EIN Application Process by Angie Adames, CPA

Posted on April 10, 2019 by Angie Adames

Effective May 13, 2019, the IRS will only issue Employer Identification Numbers (EINs) to entities whose applications name a responsible party who has a Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN). No longer will the IRS accept Form SS-4 or online applications from entities that use their existing EINs to obtain additional […]

U.S. Beneficiaries of Foreign Trusts May Be In for an Unpleasant Surprise This Year by Arthur Dichter, JD

Posted on February 14, 2019 by Arthur Dichter

The Tax Cuts and Jobs Act (TCJA) has had broad-reaching impact on all taxpayers for 2018 and going forward. This includes U.S. persons who are beneficiaries of foreign non-grantor trusts. As a result of the TCJA suspending the deduction for miscellaneous itemized deductions, which includes the deduction for investment management fees, trust distributable net income […]

Voluntary Disclosure of Previously Unreported Offshore Assets Just Got More Expensive by Andrew Leonard, CPA

Posted on January 04, 2019 by Andrew Leonard

Sept. 28, 2018, marked the end of the IRS’s Voluntary Offshore Disclosure Program (OVDP), which provided reticent taxpayers with protection from criminal prosecution and an opportunity to pay reduced penalties when they came forward to report and pay taxes on unreported foreign income and assets. As a result, the IRS has put into place new, […]

Foreign Investors Must Look before they Leap into the U.S.’s Thriving Real Estate Market by Arthur Dichter, JD, LLM

Posted on October 17, 2017 by Arthur Dichter

Commercial and residential real estate in the U.S. continues to be a safe haven for foreign investors who seek the potential for higher yields and capital preservation than they may receive in their home countries or from portfolio investments. However, the potential upside from an investment in the U.S. real estate market comes with the […]

Asymmetric Global Financial Reporting Regimes Provide Privacy Protection Opportunity by Ken Vitek, CPA

Posted on October 12, 2017 by Ken Vitek

Due to global efforts to combat tax avoidance and uncover assets hidden in offshore accounts, individuals and financial institutions continue to face a complex and challenging environment for cross-border tax reporting and compliance. There are presently more regulations centered on tax transparency and reducing countries’ lost tax revenues than ever before. However, there remains a […]

Deadline for Reports of Foreign Financial Accounts Delayed for Victims of Hurricane Irma by James W. Spencer, CPA

Posted on September 15, 2017 by Jim Spencer

U.S. citizens and resident aliens who live in areas affected by Hurricane Irma will receive an extension of time to report their financial interest in or signature authority over foreign bank, securities or other financial accounts with an aggregate value exceeding $10,000 during any time in 2016. The Financial Crimes Enforcement Network (FinCEN) announced […]

Category: International Tax